U.S. Civil Rights Commissioner Peter Kirsanow urged President Barack Obama not to grant temporary amnesty and work permits to millions more illegal immigrants via executive action, asserting Obama’s timing could not be any worse for American workers, especially black Americans.

In a Tuesday letter to Obama, Kirsanow emphasized “the disastrous effect of illegal immigration on the employment of all Americans, but particularly black Americans.” He also said that the “proposed executive order is unfair to people who are attempting to immigrate legally.”

“Any grant of legal status will serve as a magnet to prospective illegal immigrants and further depress employment opportunities and wages for African-Americans,” he wrote. “Given that the labor force participation rate is at an historic low, the unemployment rate is 6.2 percent, and there has been a precipitous decline in household wealth, the timing for such a grant of legal status could not be worse.”

Kirsanow reminded Obama that in 2008, “Well-regarded scholars from leading universities and independent groups” who “were ideologically diverse … acknowledged that illegal immigration has a negative impact on black employment, both in terms of employment opportunities and wages.”

He noted that nearly half of Black and three-fourths of illegal immigrant Hispanic males do not have an education beyond high school and, as a result, “illegal immigration has a disparate impact on African-American men” who would directly compete with illegal immigrant Hispanic males for scarce jobs.

“Granting legal status to millions of people who are in the United States illegally will continue to depress the wages and employment opportunities of African-American men and teenagers,” he wrote. “It also will depress the wages and employment opportunities of African-Americas [sic] going forward.”

Kirsanow also blamed the “flood of illegal immigrants across our southern border” on Obama’s Deferred Action for Childhood Arrivals (DACA).

“This is unsurprising,” he said. “When you incentivize bad behavior, you get more of it.”

Referencing the Obama administration’s directive on easing criminal background checks in hiring decisions because such checks disproportionately impact black Americans, Kirsanow said the “irony is that your administration’s policies operate at cross-purposes.”

“In one part of the executive branch, the EEOC issues misguided policies in an attempt to increase employment opportunities for African-American men, and in another part of the executive branch, you prepare to issue an executive order that will decrease employment opportunities and wages for those very same African-American men,” he said.

Since “disparate impact theory holds that a facially neutral policy can nonetheless constitute unlawful discrimination if it disproportionately affects a particular group,” Kirsanow wrote that Obama’s “proposed executive order will do just that.”

“It will necessarily disproportionately benefit people who are Mexican and Central American, which means that it will disproportionately disadvantage other ethnic groups,” he added. “In other contexts, this would be considered a violation of Title VII.”

Kirsanow, writing as “one member of the eight-member U.S. Commission on Civil Rights and not on behalf of the Commission as a whole,” urged Obama to reconsider his executive amnesty. Kirsanow has previously urged the Congressional Black Caucus to vote against comprehensive amnesty legislation for the same reasons.